What happened
A Washington, D.C., federal judge partially dismissed a negligence suit against the Washington Metropolitan Area Transit Authority, ruling that the plaintiffs had not adequately pleaded negligent infliction of emotional distress after an alleged Metrobus collision.
U.S. District Judge Richard J. Leon granted WMATA's second motion to dismiss the emotional-distress claim, saying the plaintiffs failed to respond to the motion and that the claim also fell short on the merits. The ruling denied WMATA's first dismissal motion as moot and denied the plaintiffs' motion for leave to amend as moot.
Michael Chase, Teonna Chase and their minor child sued WMATA after allegedly being struck by a Metrobus that merged lanes without yielding on Dec. 8, 2024. According to the opinion, they filed in D.C. Superior Court in July 2025, and WMATA removed the case to federal court the next month.
The procedural fight turned on an amended complaint filed after WMATA's first Rule 12(b)(6) motion. Judge Leon said the amendment was timely as of right under Federal Rule of Civil Procedure 15 because it was filed 14 days after WMATA's first dismissal motion, making both that motion and the plaintiffs' request for leave to amend moot.
On the remaining motion, the court said the plaintiffs never responded to WMATA's partial dismissal bid. Judge Leon also found the pleading deficient under D.C. law governing negligent infliction of emotional distress, which requires serious and verifiable distress tied to a zone of physical danger and fear for one's own safety.
The opinion said the plaintiffs' allegations of harm were "far too vague and conclusory" to support the emotional-distress claim. Judge Leon pointed to allegations that the plaintiffs were physically shaken, that the minor child cried and screamed and was medically evaluated, and that the plaintiffs continued to experience pain, emotional distress and disruption, but said similar conclusory allegations have been dismissed in other cases.
Judge Leon said an accompanying order would issue at the same time as the opinion. The packet does not include that order or establish the current status of any remaining negligence claim.